Posted Monday, June 13, 2022
The Quality, Safety & Oversight (QSO) Group at the Centers for CMS has issued a revised QSO -20-41-All memo to provide additional guidance and clarifications on the emergency preparedness standard for testing requirements due to the ongoing COVID-19 public health emergency (PHE).
If a provider experiences an actual natural or man-made emergency that requires activation of their emergency plan, inpatient and outpatient providers will be exempt from their next required full-scale community-based exercise or individual, facility-based functional exercise following the onset of the actual event. In light of the PHE, CMS is clarifying the testing exercise requirements to ensure that surveyors, providers, and suppliers are aware of the exemption available based on the activation of their emergency plans.
The updated guidance only applies if a facility is still currently operating under its activated emergency plan or reactivated its emergency plan for COVID-19 in 2021 or 2022. Facilities which have resumed normal operating status (not under their activated emergency plans) are required to conduct their testing exercises based on the regulatory requirements for their specific provider or supplier type. The guidance provides clarifications on testing exemptions for those providers/suppliers who continue to operate under their activated emergency plan and those which may have reactivated their emergency plans for COVID-19. The guidance will also apply for any subsequent 12-month cycles in the future, in the event facilities continue to operate under their activated emergency plans for COVID-19 response activities.
For outpatient providers, which include home health and hospice agencies, if the facility claimed the full-scale exercise exemption in 2020 based on its activated emergency plan for COVID-19 response and has since resumed normal operating status, the outpatient provider/supplier is expected to complete its required full-scale exercise in 2022, unless it has reactivated its emergency plan for an actual emergency during its 12-month cycle for 2022. If the facility claimed the full-scale exercise exemption in 2021 based on its activated emergency plan for COVID-19 response and has since resumed normal operating status, the outpatient provider/supplier is expected to complete its required full-scale exercise in 2024.
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